Uniform Guidance codifies a wide range of federal regulations for grant administration. Under “expanded authorities,” many federal agencies have transferred authority to recipient institutions to unilaterally approve a number of pre-award and post-award actions. One of these is the ability to authorize spending on a federal award before the start date arrives or before the award has been fully negotiated. These expenses are incurred in order to avoid delays in the performance of the award.
The Office of Sponsored Programs can grant two types of pre-award spending to investigators. One is called an “advance fund,” which allows PI/PDs to begin spending if an award is imminent. This usually occurs while an award is in a negotiation phase, where OSP has received notice that the award is incoming, but the final award documents have not yet been fully executed. Approved advance fund requests give PI/PDs a budget, typically covering 3 months, to begin the award scope of work.
The Office of Sponsored Programs can also allow “pre-award costs,” authorizing a Principal Investigator/Project Director (PI/PD) to begin spending on their award up to 90 days before the start date of the award, as sponsor terms and federal guidelines permit.
Advance funds and pre-award costs are allowed only at the discretion of OSP, the department, and federal and sponsor guidelines.
If the project involves the use of human and/or animal subjects, IRB and/or IACUC approval must be in place before a pre-award spending request can be approved.
Requests for prior approval of an “advance fund” or “pre-award costs” are at the institution’s risk, and must be justified programmatically, not for mere convenience. Expected costs must be reasonable and allowable.
Requesting an Advance Fund
To request the authorization of an “advance fund,” PI/PDs must provide to OSP:
- Institutional Prior Approval System (IPAS) form approved by the Principal Investigator/Project Director, Department Chair, and Dean
- Sufficient supporting documentation from the sponsoring agency/entity of a pending award that includes the expected start date of the project (e-mail correspondence is sufficient)
- A 3-month budget, beginning at the expected start date for the period of performance*
*If necessary, more time can be requested for the advance fund.
Requesting Pre-Award Costs
To request the authorization of “pre-award costs,” PI/PDs must provide to OSP:
- Institutional Prior Approval System (IPAS) form approved by the Principal Investigator/Project Director, Department Chair, and Dean
- Budget for expenses that will be incurred as pre-award costs before the official start date of the award
Upon completion, the IPAS form and other documentation should be forwarded to the Office of Sponsored Programs at osp@montclair.edu. The Director of Sponsored Programs will review the request. If approved, the request will be sent to the Office of Grant Accounting for processing. The PI/PD will be notified of the approval and can begin spending when the worktags have been assigned by their Grant Accountant. If the award does not materialize for any reason, the Provost will confer with the appropriate Dean(s) and/or Department Chair(s) to determine how incurred costs will be allocated.
Should the Director of Sponsored Programs not approve the request, the request may be unilaterally approved by the Dean of the Principal Investigator’s affiliated college. Should the award not materialize for any reason, the Dean will be responsible for 100% of incurred costs.
If you have any questions about the IPAS, or completing the attached form, please feel free to contact OSP at osp@montclair.edu or 973-655-4128.